Final RETA Breeze_V2_MarchApril _2025

and local emergency response agencies about accidental releases and partnering with these response agencies to ensure that a community notification system is in place to warn the public within the area potentially threatened by the accidental release. Documentation of the partner ship shall be maintained in accordance with § 68.93(c).” STRATEGIES FOR COMPLIANCE To comply with these changes, the facility’s Emergency Action Plan (EAP) needs to be reviewed, and possibly updated. First, ensure that all agencies that may need to be notified are included in the emergency notification list. This includes the National Response Center, the State Emergency Response Commission (SERC), as defined in each state, and the Local Emergency Planning Committee (LEPC), as defined by each state, and often by each county or city. It is important to bear in mind that if a facility is located close to a border, there may be multiple SERCs or LEPCs that would potentially need to be notified. In addition, some states have additional reporting require ments, often Department of Natural Resources or some other environmental related agency. Also, the triggers for notifying the U.S. Chemical Safety Board (CSB) and how do so should also be included. A flowchart detailing the triggers for CSB notification is included in Figure 1. Second, when to call must also be clearly defined in the EAP. The first option would be to simply identify the triggers set by the Federal government for calling the NRC, and as set by the state for calling the SERC and the LEPC. For instance, the EAP for a facility could state that the NRC must be called if the incident has released more than 100 pounds of ammonia in less than 24 hours. If the facility is in Massachusetts, the state and local calls would be triggered if more than 10 pounds of ammonia was released in less than 24 hours. How to determine those amounts? Often it is difficult, if not impossible, to have an accurate idea of how much has been released. Option 2 would be to call every time ammonia is released. However, with these calls being public record, it would not reflect well on the facility’s owner or operator if every nuisance packing leak

AMMONIA RELEASE/INCIDENT CSB REPORTING PROCESS CHART

Significant Property Damage? See Definition

NO

NO

NO

AMMONIA RELEASE OR INCIDENT

Serious injury? See Definition

No CSB Report Necessary

Fatality?

YES

YES

YES

CSB Reporting Definitions:

DEFINITIONS Release - only spilling, looking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, Significant property damage is defined as equal to or greater then $1,000,000 Reportable quantity (RQ) - chemical release above the threshold that triggers federal and/or State emergency release notifications requirements Serious injury is defined as formal admission to the hospital for inpatient treatment or disposing into the environment.

(3) CSB 202 261 /600 Report@csb.gov

Call or email within 30 minutes of notifying the NRC

YES

Follow Up Report

NRC Notified?

Within 30 days

Call or email within 8 hours of becoming aware of the release

NO

Required to the report the following: 1.

7. Chemical: Anhydrous Ammonia, CAS# 7664-41-7 Estimated quantity released to environment — stating “Unknown at this time” is allowed If known, the number of fatalities 10. If known, the number of serious injuries 11. Estimated property damage at or outside of the facility 12. Whether the release has resulted in an evacuation order, and, if known: 1. The number of persons evacuated 2. Approximate radius of the evacuation zone 3. The type of person subject to evacuation (i.e., employees, members of the general public, or both) 8. 9.

Your name & contact information of Owner/operator Your name & contact information of person making the report Location information and facility identifier Approximate time of release. Brief description of accidental release Indication of whether one or more of the following occurred: 1. Fire; 2. Explosion; 3. Death; 4. Serious injury; or 5. Property Damage;

2.

3.

4. 5.

6.

NRC - National response center NH 3 - Ammonia Chemical Formula CSB - Chemical Safety Board

Figure 1: USCSB Notification Flowchart

Other criteria that could be added to the above list based upon the difficulty of determining a release amount: • Any safety relief valve lift to atmo sphere • Condenser tube leak Finally, be sure to include in the EAP a list of personnel who are authorized and trained to make the notifications and include a statement in the EAP indicating that the local first responders will notify the public, if they deem it warranted, in the event of an accidental release. With these new requirements, be sure to comply with the coordination require ments in 40 CFR 68.93, or at least document the annual attempts to do so, and conduct the notification exercise

was reported. A better option would be to create easy to follow guidelines for calling that ensure that all reportable releases are reported but limits how many incidents that don’t require notification are reported. Some example criteria that could be used to trigger notification are as follows: • Measured PPM over the IDLH, or over the limits of the facility’s PPE, whichever is lower. • Pool or a spray of liquid ammonia • Visible cloud of ammonia (not including whisps from a valve packing) Leak does not meet the above criteria but lasts longer than a pre-determined number of minutes •

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